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Agenda 04/22/2025 Item #16K 7 (Approve Stipulated Order of Taking and Final Judgment totaling $121,379 for Parcel 1359FEE1 needed for the Vanderbilt Beach Road Extension Project No. 60249.)4/22/2025 Item # 16.K.7 ID# 2025-1379 Executive Summary Recommendation to approve a Stipulated Order of Taking and Final Judgment in the amount of $103,000 plus $18,379 in statutory attorney and experts’ fees and costs for the taking of Parcel 1359FEE1 required for the Vanderbilt Beach Road Extension Project No. 60249. OBJECTIVE: To settle full compensation for the taking of Parcel 1359FEE1 required for the construction of the Vanderbilt Beach Road Extension Project No. 60249. CONSIDERATIONS: On July 9, 2024, the Board authorized, via Resolution No. 2024-135, the condemnation of Parcel 1359FEE1 for the construction of roadway, drainage and utility improvements required for the expansion and extension of Vanderbilt Beach Road from 16th Street NE to Everglades Blvd. The fee simple acquisition area consists of a strip taking along the rear, southern boundary of the property and is approximately 0.38 acres in extent. The parent tract is vacant land owned by Delbi and Anny Javier and contains 2.50 acres of gross land area, which will be reduced to 2.12 acres after the acquisition. An aerial photograph of the subject property is attached. The County’s appraiser estimated full compensation at $72,700 including severance damages. The property owner’s initial demand was $164,900 plus attorney’s fees and expert fees and costs. The parties participated in informal negotiations and reached an agreement. The attached Stipulated Order of Taking and Final Judgement reflects a negotiated compensation amount of $103,000 plus $9,999 in statutory attorney’s fees, $8,380 in expert fees and costs, for a total of $121,379. Staff recommends approval of this Stipulated Final Judgment since a better result is not anticipated at trial. Upon approval, the County Attorney’s Office will file the Joint Motion and Stipulated Final Judgment with the Circuit Court. This item is consistent with the Collier County strategic plan objective to design and maintain an effective transportation system to reduce traffic congestion and improve the mobility of our residents and visitors. FISCAL IMPACT: Funds of $121,549 are required, being the compensation amount of $121,379 including statutory attorney’s fees, expert fees and costs, and the Clerk’s $170.00 deposit fee. The primary funding source for the acquisition of right of way is through Road Impact Fee District Funds (3090, 3091, 3092, 3093, 3094, 3095) in the Vanderbilt Beach Road from 16th to Everglades Project (60249). Should impact fees not be sufficient, the secondary funding source will be Road Construction Gas Tax Fund (3083) and Transportation Capital Fund (3081). GROWTH MANAGEMENT IMPACT: There is no growth management impact associated with this action. LEGAL CONSIDERATIONS: This item is approved as to form and legality and requires majority vote for approval. – CMG RECOMMENDATIONS: To approve the attached Joint Motion and Stipulated Final Judgment and authorize the payment of funds as stated herein. PREPARED BY: Robert Bosch, Manager, ROW Acquisition, Operations & Performance Management Division ATTACHMENTS: 1. Signed P1359FEE1 - Joint Motion for STIP OT and FJ(4) - Final 2. Aerial - Parcel 1359FEE1 Page 5784 of 6355 [25-CA-222/1926824/1] IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR COLLIER COUNTY, FLORIDA CIVIL ACTION Collier County, Florida, a political Subdivision of the State of Florida, Plaintiff, Case No. 25-CA-222 vs. Parcel: 1359FEE1 Chavers LLC; Aurelio Rendon Pascual; Margarita Rojas; Fernando Hernandez, LLC; Unknown Tenant(s); QFC Properties, LLC; Lux-Naples, LLC, a Florida limited liability company (dissolved); Mortgage Electronic Registration Systems, Inc; Luciano Zela; Juan A. Miranda Ortiz; Loida Jeannot; Florida Pace Funding Agency; Delbi Javier; Anny Javier; Rendon Real Estate LLC; and Rob Stoneburner, Collier County Tax Collector, Respondents. ______________________________________________/ JOINT MOTION FOR A STIPULATED ORDER OF TAKING AND FINAL JUDGMENT AS TO PARCEL 1359FEE1 COMES NOW, Petitioner, COLLIER COUNTY, FLORIDA, together with Respondents, DELBI JAVIER AND ANNY JAVIER, by and through undersigned counsel, and hereby respectfully move for entry of the Stipulated Order of Taking and Final Judgment, attached hereto as Exhibit “1”. _______________________________ COLLEEN M. GREENE, ESQ. Florida Bar No. 502650 Collier County Attorney’s Office 3299 E. Tamiami Trail, Suite 800 Naples, FL 34112 Telephone: (239) 252-8400 COUNSEL FOR PETITIONER Colleen.Greene@colliercountyfl.gov Sheri.Malcolm@colliercountyfl.gov ________________________________ ANTHONY V. POLICASTRO, ESQ. Florida Bar No. 937932 Policastro Law Group 1700 N McMullen Booth Rd Ste C5 Clearwater, FL 33759-2129 Office: 727-475-1988 Fax: 727-674-1771 tony@policastrolaw.com eric@policastrolaw.com yadi@policastrolaw.com Page 5785 of 6355 [25-CA-222/1926824/1] CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the Joint Motion for Stipulated Order of Taking and Final Judgment was electronically filed with the Florida Courts E-Filing Portal on this _____ day of ___________________ 2025. BY: _______________________________ COLLEEN M. GREENE, ESQ. Page 5786 of 6355 [25-CA-222/1926824/1] IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR COLLIER COUNTY, FLORIDA CIVIL ACTION Collier County, Florida, a political Subdivision of the State of Florida, Plaintiff, Case No. 25-CA-222 vs. Parcel: 1359FEE1 Chavers LLC; Aurelio Rendon Pascual; Margarita Rojas; Fernando Hernandez, LLC; Unknown Tenant(s); QFC Properties, LLC; Lux-Naples, LLC, a Florida limited liability company (dissolved); Mortgage Electronic Registration Systems, Inc; Luciano Zela; Juan A. Miranda Ortiz; Loida Jeannot; Florida Pace Funding Agency; Delbi Javier; Anny Javier; Rendon Real Estate LLC; and Rob Stoneburner, Collier County Tax Collector, Respondents. ______________________________________________/ STIPULATED ORDER OF TAKING & FINAL JUDGMENT FOR PARCEL 1359FEE1 (with disbursement instructions to Clerk) THIS CAUSE having come before the Court upon the Joint Motion made by Petitioner, COLLIER COUNTY, FLORIDA, and Respondents, DELBI JAVIER AND ANNY JAVIER, by and through counsel, for entry of a Stipulated Order of Taking and Final Judgment as to Parcel 1359FEE1 for Project No. 60249, and it appearing to the Court that proper notice was given to the parties having any equity, lien, title or other interest in or to the real property described therein, and the Court being otherwise fully advised in the premises thereof, it is therefore ORDERED AND ADJUDGED that: 1. The Court has jurisdiction of this cause, the parties hereto and the subject matter hereof. 2. The pleadings in this cause are sufficient and the Petitioner is properly exercising its delegated authority. Page 5787 of 6355 [25-CA-222/1926824/1] 3. The property described herein as Parcel 1359FEE1 is being acquired for a public purpose and is reasonably necessary to serve this public purpose. 4. The Declaration of Taking and Estimate of Value filed in this cause by the Petitioner was made in good faith and based on a valid appraisal. 5. Respondents, DELBI JAVIER AND ANNY JAVIER shall recover from Petitioner, COLLIER COUNTY, FLORIDA, the total sum of One Hundred Three Thousand Dollars and No/100 ($103,000.00) for Parcel 1359FEE1, as full payment for the property interest taken and for any damages resulting to the remainder, and for all other damages and costs in connection with said parcel. 6. Respondents, DELBI JAVIER AND ANNY JAVIER shall recover from Petitioner, COLLIER COUNTY, FLORIDA, the total sum of Nine Thousand Nine Hundred Ninety-Nine Dollars and No/100 ($9,999.00) for all attorney’s fees and costs, and no other attorney’s fees or costs shall be paid in connection with said parcel. 7. Respondents, DELBI JAVIER AND ANNY JAVIER shall recover from Petitioner, COLLIER COUNTY, FLORIDA, the total sum of Eight Thousand Three Hundred Eighty Dollars and No/100 ($8,380.00) for all expert fees and costs, and no other expert fees or costs shall be paid in connection with said parcel. 8. The right and title to Parcel 1359FEE1, being fully described in Exhibit “A” attached hereto and incorporated herein, will vest in Petitioner COLLIER COUNTY upon deposit of the amounts specified above into the Registry of this Court. 9. Within twenty (20) days from the date of this Order, Petitioner, COLLIER COUNTY, FLORIDA, shall deposit into the Court Registry the total sum of One Hundred Twenty-One Thousand Three Hundred Seventy-Nine Dollars and No/100 ($121,379.00), as Page 5788 of 6355 [25-CA-222/1926824/1] payment for acquisition of Parcel 1359FEE1, at which time title to said parcel as described in Exhibit “A” is vested in the name of the Petitioner. 10. Upon deposit, the Clerk of Courts shall disburse from the Court Registry as follows: a. The Clerk shall disburse the sum of Fifty-Two Dollars and 50/100 ($52.50) (based on a $0.50 per day for 105 days for the period of Jan. 1, 2025, through April 15, 2025) to the Collier County Tax Collector. b. The Clerk shall disburse the remaining balance of One Hundred Twenty-One Thousand Three Hundred Twenty-Six Dollars and 50/100 ($121,326.50), to Respondents, DELBI JAVIER AND ANNY JAVIER, by issuing a check made payable to the Trust Account of Policastro Law Group, LLC, and mailing it to Anthony Policastro, Esq., c/o Policastro Law Group, 1700 N McMullen Booth Rd Ste C5, Clearwater, FL 33759-2129. 11. County's initial construction of the subject project shall substantially conform with the County's 90% construction plans, filed with the Court on March 26, 2025. In the event the initial project is not so constructed, Respondents reserve the right to claim additional damages, if any, including attorney’s fees, in accordance with Central & Southern Florida Flood Control District v. Wye River Farms, Inc., 297 So.2d 323 (Fla. 4th DCA 1974). The 90% construction plans provide for two travel lanes; however, the right-of-way footprint is sufficient to accommodate up to a six-lane road design. No additional compensation shall be due to Respondents for the future widening of Vanderbilt Beach Road up to four-lanes or six-lanes, including related roadway improvements to Vanderbilt Beach Road. 12. This Stipulated Order of Taking and Final Judgment disposes of all claims arising out of the taking of Parcel 1359FEE1 and that have or could have been asserted in this cause. Page 5789 of 6355 [25-CA-222/1926824/1] 13. The Notice of Lis Pendens filed in the above-styled cause and recorded in Official Record Book 6438, Page 2020 of the Public Records of Collier County, Florida is hereby released as to Parcel 1359FEE1. 14. The Court reserves jurisdiction to enforce the terms of this Stipulated Order of Taking and Final Judgment. 15. This Stipulated Order of Taking and Final Judgment is to be recorded in the Official Records of Collier County, Florida. Page 5790 of 6355 [25-CA-222/1926824/1] Exhibit “A” Page 5791 of 6355 AERIAL – PARCEL 1359FEE1 (Vanderbilt Beach Road Extension Phase 2 Project No. 60249) 10th Ave NE PARCEL 1359FEE1 / Page 5792 of 6355